Hong Kong Case Law: Decisions & Judgments

Topic

Dissipation of assets

Legal area

Court

2 Mar 2026

TW RECOVERY LTD AND OTHERS v. BEST LEADER PRECIOUS METALS LTD AND OTHERS

Citation

[2026] HKCA 361
Court

Court of Appeal
Case number

CACV369/2023

The Court allowed the appeal in part: the plaintiffs (TWR) had provided an acceptable evidential basis to justify a reduced broad‑brush monetary ceiling for Mareva relief; non-disclosure of the double actionability point and of the plaintiffs' roles did not justify discharging the Mareva injunctions; there was a good arguable case against D10; accordingly the Mareva injunctions were continued against D8 and D10 and not discharged as against D9 but the monetary limit was reduced to US$150,000,000.
26 Feb 2026

CHOW PO TAI v. CHEN CAO LIYAN AND ANOTHER

Citation

[2026] HKCFI 1084
Court

Court of First Instance
Case number

HCA2379/2024

Leave to appeal was refused because the appellant failed to show reasonable prospects of success; the judge was entitled to find material non-disclosure on the relationship between P and D1 and on the transfer of HK$2,715,927.08 based on the evidence, and the refusals to continue or re-grant the ex parte order and to grant interim-interim relief were within the reasonable ambit of judicial discretion and not plainly wrong.
26 Jan 2026

ETERNAL INTERNATIONAL HOLDINGS LTD v. LO KON KI AND ANOTHER

Citation

[2026] HKCFI 579
Court

Court of First Instance
Case number

HCA600/2025

Plaintiff is prima facie ordinarily resident out of jurisdiction and, having regard to its status as a paper/shelf BVI company, the timing and nature of the Property acquisition and lack of evidence of other assets or means of payment, there is reason to believe Plaintiff may be unable to pay Defendant's costs; in all the circumstances it is just to order security for costs in the reduced sum of HK$900,000 and make a costs order nisi in respect of the summons.
11 Jul 2025

北京誠義豪泰投資管理有限公司 v. ZHANG YUPING (also known as CHEUNG YU PING)

Citation

[2025] HKCFI 3002
Court

Court of First Instance
Case number

HCCT1/2025

The court granted an interim stay because the leave application would likely be rendered nugatory absent a stay given the realistic risk of asset dissipation (including access requests by companies associated with the defendant and recent transfers of shares), at least one ground of appeal appeared to have arguable prospects, and any prejudice to the defendant would be short-lived because the stay is interim pending a prompt paper disposal of the leave application.
17 Feb 2025

DIAMOND TREASURE LTD v. MAN KAM LEUNG AND ANOTHER

Citation

[2025] HKDC 264
Court

District Court
Case number

DCCJ4419/2014

The court joined the 1st respondent for costs purposes (first stage) because the application was not an abuse or unduly delayed, but on the second stage dismissed the plaintiff's application: the plaintiff failed to prove the 1st respondent was the real party or that there was serious impropriety/bad faith causatively linked to incurring the costs; adverse possession defence had legal foundation; allegations of asset dissipation were disputed and outside the litigation period and could not support a non‑party costs order in the interest of justice; therefore no non‑party costs order made agai…
24 Jan 2025

JULIAN TECHNOLOGY PTY LTD v. MANWAY TRADING LTD AND ANOTHER

Citation

[2025] HKDC 163
Court

District Court
Case number

DCCJ6201/2024

The interim Mareva injunction was refused because the plaintiff failed to establish a serious issue to be tried against the 2nd defendant on the pleaded unlawful means claim and failed to demonstrate a real risk of dissipation; the court emphasised deference to directors' business judgments and the protection of separate legal personality, and found the timing and registration of the sale lawful under the Land Registration Ordinance.
30 Aug 2024

HYF v. CSL

Citation

[2024] HKFC 162
Court

Family Court
Case number

FCMC14931/2014

Applying section 7 MPPO and LKW principles the court identified and adjusted the parties' asset ledgers (adding back quantified sums for non-disclosure and dissipation), concluded surplus exists after needs are met, applied the sharing principle but departed from equality because of W's greater contributions, H's gross misconduct (maintenance to mistress and child), abusive litigation in Shanghai and material non-disclosure; after adjustments the matrimonial pot was HK$174,930,171.36 and respondent (H) was awarded one quarter of the pot, payable as a lump sum of HK$22,508,000 by W within 28 d…
23 Aug 2024

WU JUN v. CAPTAIN HOLDINGS LTD (In Compulsory Liquidation) AND OTHERS

Citation

[2024] HKCFI 2184
Court

Court of First Instance
Case number

HCA106/2022

Court continued the mareva injunction against the 10th and 11th Defendants until final determination because the plaintiff established a good arguable case of knowing assistance in a fraud, there was a solid basis to infer a real risk of unjustified dissipation of assets by those defendants, and the balance of convenience favored continuation; alleged material non-disclosure did not defeat the injunction on the evidence before the court.
26 Jun 2024

ACE EARN LTD v. SIU CHI MING

Citation

[2024] HKCFI 1674
Court

Court of First Instance
Case number

HCA1333/2023

The court found plaintiffs have a good arguable case of breaches of directors' duties in respect of the Rice Contracts, Innomind transactions and retrospective payouts; the defendant's incomplete and delayed asset disclosure and emigration to Australia establish a real risk of dissipation; the balance of convenience therefore requires continuation of Mareva injunctions, with a limited variation to credit the HK$3,039,840 payment; costs awarded to plaintiffs.
28 May 2024

SL v. CPYD

Citation

[2024] HKFC 111
Court

Family Court
Case number

FCMC12136/2011

Limited discovery was ordered where a prima facie case of dissipation or possession existed and the requests were necessary and proportionate (Husband ordered to disclose receiving account and October–November 2019 bank statements for SZ property proceeds and documents evidencing the RMB3,000,000 bridging loan; Wife ordered to disclose audited accounts of MCA from 2013 to present). Extensive, historic or speculative requests that were irrelevant, disproportionate, non-existent or obtainable by other means were refused (most items in the Husband's SD summons and specific items in the NP summon…